From the Editor’s Desk – Conversion and Dismissal

By The Honorable William Houston Brown (Retired)

Party in interest standing to file motion to dismiss, despite no allowed claim. Under § 1306(c), the moving party had standing as a party in interest to move for case dismissal, despite the fact that it had not filed a proof of claim and the bar date for claims had passed, with the court applying In re Torres Martinez, 397 B.R. 158 (BAP 1st Cir. 2008). The moving creditor still had a sufficient pecuniary interest in the case, since dismissal before entry of discharge would permit . . .

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